The IRS recently released proposed regulations under section 861 that address digital transactions. This Bottom Line videocast discusses:
the proposed expansion of the scope of existing Treas. Reg. § 1.861-18, which focuses on the classification of transactions involving computer programs, to apply to all transfers of “digital content”;
the sourcing rules applicable to such transfers; See more +
The IRS recently released proposed regulations under section 861 that address digital transactions. This Bottom Line videocast discusses:
the proposed expansion of the scope of existing Treas. Reg. § 1.861-18, which focuses on the classification of transactions involving computer programs, to apply to all transfers of “digital content”;
the sourcing rules applicable to such transfers; and
Prop. Treas. Reg. § 1.861-19, which provides guidelines for classifying cloud transactions as either services or as a lease. See less -